Information Security Policy

on

Outsourcing

Summary
This policy mandates the assessment and management of
commercial and information security risks associated with
business process outsourcing.
 Outsourcing security policy

Index

1 Introduction....................................................................................................................3
2 Objective..........................................................................................................................3
3 Scope................................................................................................................................3
4 Policy axioms..................................................................................................................4
5 Policy statements............................................................................................................4
5.1 Choosing an outsourcer.........................................................................................4
5.2 Assessing outsourcing risks...................................................................................4
5.3 Contracts and confidentiality agreements...........................................................5
5.4 Hiring and training of employees.........................................................................7
5.5 Access controls.........................................................................................................8
5.6 Security audits.........................................................................................................9
6 Responsibilities...............................................................................................................9
6.1 Management............................................................................................................9
6.2 Outsourced business process owners..................................................................9
6.3 Information Security ............................................................................................10
6.4 Internal Audit........................................................................................................10
7 Copyright .....................................................................................................................10
8 Disclaimer......................................................................................................................10

Version Issue Prepared by Approved by Description

Date
1 23rd Aaron d’Souza Generic sample policy
March and Gary published at
2008 Hinson www.ISO27001security.com

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 Outsourcing security policy

1 Introduction
1.1.1 Outsourcing involves transferring responsibility for carrying out an activity
(previously carried on internally) to an outsourcer for an agreed charge.
The outsourcer provides services to the customer based on a mutually
agreed service level, normally defined in a formal contract.

1.1.2 Many commercial benefits have been ascribed to outsourcing, the most
common amongst these being:
 Reducing the organization’s costs
 Greater focus on core business by outsourcing non-core functions
 Access to world-class skills and resources

1.1.3 Despite the potential benefits, information security incidents such as

inappropriate access to or disclosure of sensitive information, loss of
intellectual property protection or the inability of the outsourcer to live up to
agreed service levels, would reduce the benefits and could jeopardize the
security posture of the organization.

2 Objective
2.1.1 This policy specifies controls to reduce the information security risks
associated with outsourcing.

3 Scope
3.1.1 The policy applies throughout <ORGANIZATION>.

3.1.2 Outsourcing providers (also known as outsourcers) include:

 hardware and software support and maintenance staff
 external consultants and contractors
 IT or business process outsourcing firms
 temporary staff

3.1.3 The policy addresses the following controls found in the ISO/IEC
27002:2005 and ISO/IEC 27001 standards:
 6.2.1 Identification of risks related to external parties
 6.2.2 Addressing security when dealing with customers

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 Outsourcing security policy

 6.2.3 Addressing security in third party agreements

4 Policy axioms
4.1.1 The commercial benefits of outsourcing non-core business functions must
be balanced against the commercial and information security risks.

4.1.2 The risks associated with outsourcing must be managed through the
imposition of suitable controls, comprising a combination of legal, physical,
logical, procedural and managerial controls.

5 Policy statements

5.1 Choosing an outsourcer

5.1.1 Criteria for selecting an outsourcer shall be defined and documented,

taking into account the:
 company’s reputation and history;
 quality of services provided to other customers;
 number and competence of staff and managers;
 financial stability of the company and commercial record;
 retention rates of the company’s employees;
 quality assurance and security management standards currently
followed by the company (e.g. certified compliance with ISO 9000 and
ISO/IEC 27001).

5.1.2 Further information security criteria may be defined as the result of the risk
assessment (see next section).

5.2 Assessing outsourcing risks

5.2.1 Management shall nominate a suitable <ORGANIZATION> owner for each

business function/process outsourced. The owner, with help from the local
Information Risk Management Team, shall assess the risks before the
function/process is outsourced, using <ORGANIZATION>’s standard risk
assessment processes.

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5.2.2 In relation to outsourcing, specifically, the risk assessment shall take due
account of the:
a) nature of logical and physical access to <ORGANIZATION>
information assets and facilities required by the outsourcer to fulfill
the contract;
b) sensitivity, volume and value of any information assets involved;
c) commercial risks such as the possibility of the outsourcer’s business
failing completely, or of them failing to meet agreed service levels or
providing services to <ORGANIZATION>’s competitors where this
might create conflicts of interest; and
d) security and commercial controls known to be currently employed by
<ORGANIZATION> and/or by the outsourcer.

5.2.3 The result of the risk assessment shall be presented to management for
approval prior to signing the outsourcing contract. Management shall
decide if <ORGANIZATION> will benefit overall by outsourcing the
function to the outsourcer, taking into account both the commercial and
information security aspects. If the risks involved are high and the
commercial benefits are marginal (e.g. if the controls necessary to
manage the risks are too costly), the function shall not be outsourced.

5.3 Contracts and confidentiality agreements

5.3.1 A formal contract between <ORGANIZATION> and the outsourcer shall

exist to protect both parties. The contract shall clearly define the types of
information exchanged and the purpose for so doing.

5.3.2 If the information being exchanged is sensitive, a binding confidentiality

agreement shall be in place between <ORGANIZATION> and the
outsourcer, whether as part of the outsource contract itself or a separate
non-disclosure agreement (which may be required before the main
contract is negotiated).

5.3.3 Information shall be classified and controlled in according with

<ORGANIZATION> policy.

5.3.4 Any information received by <ORGANIZATION> from the outsourcer

which is bound by the contract or confidentiality agreement shall be
protected by appropriate classification and labeling.

5.3.5 Upon termination of the contract, the confidentiality arrangements shall be

revisited to determine whether confidentiality has to be extended beyond
the tenure of the contract.

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5.3.6 All contracts shall be submitted to the Legal for accurate content,
language and presentation.

5.3.7 The contract shall clearly define each party’s responsibilities toward the
other by defining the parties to the contract, effective date, functions or
services being provided (e.g. defined service levels), liabilities, limitations
on use of sub-contractors and other commercial/legal matters normal to
any contract. Depending on the results of the risk assessment, various
additional controls should be embedded or referenced within the contract,
such as:
 Legal, regulatory and other third party obligations such as data
protection/privacy laws, money laundering etc.*;
 Information security obligations and controls such as:
o Information security policies, procedures, standards and
guidelines, normally within the context of an Information Security
Management System such as that defined in ISO/IEC 27001;
o Background checks on employees or third parties working on the
contract (see section 5.4);
o Access controls to restrict unauthorized disclosure, modification or
destruction of information, including physical and logical access
controls, procedures for granting, reviewing, updating and revoking
access to systems, data and facilities etc.(see section 5.5);
o Information security incident management procedures including
mandatory incident reporting;
o Return or destruction of all information assets by the outsourcer
after the completion of the outsourced activity or whenever the
asset is no longer required to support the outsourced activity;
o Copyright, patents and similar protection for any intellectual
property shared with the outsourcer or developed in the course of
the contract;
o Specification, design, development, testing, implementation,
configuration, management, maintenance, support and use of
security controls within or associated with IT systems, plus source
code escrow;
o Anti-malware, anti-spam and similar controls;
o IT change and configuration management, including vulnerability
management, patching and verification of system security controls
prior to their connection to production networks;

*
In the case of “offshore” outsourcing, special consideration must be given to the ramifications of
transferring information between countries or jurisdictions, particularly where privacy and similar
laws may conflict. Take qualified legal advice as a matter of course.

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 The right of <ORGANIZATION> to monitor all access to and use of

<ORGANIZATION> facilities, networks, systems etc., and to audit the
outsourcer’s compliance with the contract, or to employ a mutually
agreed independent third party auditor for this purpose;
 Business continuity arrangements including crisis and incident
management, resilience, backups and IT Disaster Recovery.

5.3.8 Although outsourcers that are certified compliant with ISO/IEC 27001 can
be presumed to have an effective Information Security Management
System in place, it may still be necessary for <ORGANIZATION> to verify
security controls that are essential to address <ORGANIZATION>’s
specific security requirements, typically by auditing them (see section 5.6).

5.4 Hiring and training of employees

5.4.1 Outsource employees, contractors and consultants working on behalf of

<ORGANIZATION> shall be subjected to background checks equivalent to
those performed on <ORGANIZATION> employees. Such screening shall
take into consideration the level of trust and responsibility associated with
the position and (where permitted by local laws):
 Proof of the person’s identity (e.g. passport);
 Proof of their academic qualifications (e.g. certificates);
 Proof of their work experience (e.g. résumé/CV and references);
 Criminal record check;
 Credit check.

5.4.2 Companies providing contractors/consultants directly to

<ORGANIZATION> or to outsourcers used by <ORGANIZATION> shall
perform at least the same standard of background checks as those
indicated above.

5.4.3 Suitable information security awareness, training and education shall be

provided to all employees and third parties working on the contract,
clarifying their responsibilities relating to <ORGANIZATION> information
security policies, standards, procedures and guidelines (e.g. privacy
policy, acceptable use policy, procedure for reporting information security
incidents etc.) and all relevant obligations defined in the contract.

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5.5 Access controls

5.5.1 In order to prevent unauthorized access to <ORGANIZATION>’s

information assets by the outsourcer or sub-contractors, suitable security
controls are required as outlined in this section. The details depend on the
nature of the information assets and the associated risks, implying the
need to assess the risks and design a suitable controls architecture.

5.5.2 Technical access controls shall include:

 User identification and authentication;
 Authorization of access, generally through the assignment of users to
defined user rôles having appropriate logical access rights and
controls;
 Data encryption in accordance with <ORGANIZATION>’s encryption
policies and standards defining algorithms, key lengths, key
management and escrow etc.
 Accounting/audit logging of access checks, plus alarms/alerts for
attempted access violations where applicable.

5.5.3 Procedural components of access controls shall be documented within

procedures, guidelines and related documents and incorporated into
awareness, training and educational activities. This includes:
 Choice of strong passwords;
 Determining and configuring appropriate logical access rights;
 Reviewing and if necessary revising access controls to maintain
compliance with requirements;

5.5.4 Physical access controls shall include:

 Layered controls covering perimeter and internal barriers;
 Strongly-constructed facilities;
 Suitable locks with key management procedures;
 Access logging though the use of automated key cards, visitor
registers etc.;
 Intruder alarms/alerts and response procedures;

5.5.5 If parts of <ORGANIZATION>’s IT infrastructure are to be hosted at a third

party data centre, the data centre operator shall ensure that
<ORGANIZATION>’s assets are both physically and logically isolated from
other systems.

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5.5.6 <ORGANIZATION> shall ensure that all information assets handed over to
the outsourcer during the course of the contract (plus any copies made
thereafter, including backups and archives) are duly retrieved or destroyed
at the appropriate point on or before termination of the contract. In the
case of highly classified information assets, this normally requires the use
of a schedule or register and a process whereby the outsourcer formally
accepts accountability for the assets at the point of hand-over.

5.6 Security audits

5.6.1 If <ORGANIZATION> has outsourced a business function to an outsourcer

based at a different location, it shall audit the outsourcer’s physical
premises periodically for compliance to <ORGANIZATION>’s security
policies, ensuring that it meets the requirements defined in the contract.

5.6.2 The audit shall also take into consideration the service levels agreed in the
contract, determining whether they have been met consistently and
reviewing the controls necessary to correct any discrepancies.

5.6.3 The frequency of audit shall be determined by management on advice

from functions such as Internal Audit, Information Security Management
and Legal.

6 Responsibilities

6.1 Management

6.1.1 Management is responsible for designating suitable owners of business

processes that are outsourced, overseeing the outsourcing activities and
ensuring that this policy is followed.

6.1.2 Management is responsible for mandating commercial or security controls

to manage the risks arising from outsourcing.

6.2 Outsourced business process owners

6.2.1 Designated owners of outsourced business processes are responsible for

assessing and managing the commercial and security risks associated
with outsourcing, working in conjunction with Information Security, Legal
and other functions as necessary.

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6.3 Information Security

6.3.1 Information Security, in conjunction with functions such as Legal,

Compliance and Risk Management, is responsible for assisting
outsourced business process owners to analyze the associated risks and
develop appropriate process, technical, physical and legal controls.

6.3.2 Information Security is also responsible for maintaining this policy.

6.4 Internal Audit

6.4.1 Internal Audit is authorized by management to assess compliance with all

corporate policies at any time.

6.4.2 Internal Audit may assist with audits of outsourcing contracts including
security compliance audits, and advise management on the risks and
controls relating to outsourcing.

7 Copyright

This work is copyright © 2008, ISO27k Implementers' Forum, some

rights reserved. It is licensed under the Creative Commons Attribution-
Noncommercial-Share Alike 3.0 License. You are welcome to reproduce,
circulate, use and create derivative works from this provided that (a) it is not sold
or incorporated into a commercial product, (b) it is properly attributed to the
ISO27k Implementers’ Forum (www.ISO27001security.com), and (c) derivative
works are shared under the same terms as this.

8 Disclaimer
This is a generic example policy. It is not intended to suit all organizations and
circumstances. It is merely guidance. Please refer to the ISO/IEC 27000-series
standards and other definitive sources including qualified legal counsel in
preparing your own security policies.

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